Articles and Blogs

What Is the “Compendium of Priority Recommendations”? In March 2014, the Department of Health and Human Services Office of the Inspector General (“OIG”) published the 2014 “Compendium of Priority Recommendations” (“Compendium”), a compilation of 25 of its most significant open recommendations that, in OIG’s view, would best protect the integrity of HHS programs, if... READ MORE

Executive Summary On May 2, 2014, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule (“Final Rule”) establishing a prospective payment system (“PPS”) for Federally Qualified Health Centers (“FQHCs”).  As a result of this rule, PPS reimbursement will be mandated for both FQHC “look-alikes” and Section 330 grant recipients effective for... READ MORE

Yesterday, CMS posted the following update to its Inpatient Hospital Reviews page:  READ MORE

On May 2, 2014, CMS published a final rule (“Final Rule”) amending the Clinical Laboratory Improvement Amendments of 1988 (“CLIA”) by fully implementing the Taking Essential Steps for Testing Act of 2012 (“TEST Act”) and establishing three categories of sanctions for proficiency testing referral (“PT referral”). READ MORE

According to a Federal Register notice published on May 5, physicians and teaching hospitals will soon be able to register with the Centers for Medicare and Medicaid Services (“CMS”) to receive notices from and access to CMS’s Open Payments database.  The Open Payments database will contain information about payments and other transfers of value that... READ MORE

On May 8, 2014, the Department of Health and Human Services (“HHS”) announced that it had reached settlements with two health care organizations arising from alleged violations of the Health Insurance Portability and Accountability Act (“HIPAA”) Privacy and Security Rules.  The settlements result from the organizations’ failure to secure thousands of patients’ electronic protected... READ MORE

The application of the Medicare therapy caps has been revised many times over the past several years.  Most recently, Congress passed the Protecting Access to Medicare Act of 2014 (“Act”), which extends exceptions to the therapy caps and continues to apply services performed in outpatient hospital departments to the therapy caps until March 31, 2015. ... READ MORE

Tax-exempt organizations should be mindful that Form 990-series information returns are due on the 15th day of the fifth month after a tax-exempt organization’s tax year ends.  Thus, if your organization operates on a calendar year basis, then your due date is May 15th.  Furthermore, organizations with a June 30 year end that previously... READ MORE

Nearly all hospitals are prohibited by federal law from discriminating in employment based on race, color, sex, religion, ethnicity, disability and age.  Those that have certain types of federal contracts must go further by engaging in affirmative action.  Compliance with federal affirmative action laws is difficult and expensive, especially when audits are involved.  Unfortunately... READ MORE

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